The German version is binding. Draft, legal review pending.

Privacy Policy

Version: September 2026. Draft, legal review pending. The German version is binding.

1. Controller

Pioneerdesk GmbH, Palmberg 29, 84539 Zangberg, Germany, represented by Marcus Lenczyk, e-mail info@pioneerdesk.eu. A data protection officer does not have to be appointed under § 38 BDSG.

2. Hosting and place of processing

The service runs on infrastructure of STACKIT GmbH & Co. KG (Schwarz Group) in data centres in Germany. No transfer to third countries takes place unless stated below. A data processing agreement pursuant to Art. 28 GDPR is in place with STACKIT.

3. Data processed and purposes

• Server logs: truncated IP address, time, requested address, status code, browser identifier. Purpose: operation and security (Art. 6 (1) (f) GDPR). Deleted after 7 days.
• User account: e-mail address, name, login times, second factor by e-mail code; managed by our self-hosted identity service (Zitadel). Purpose: performance of the contract (Art. 6 (1) (b) GDPR).
• Stored API keys: stored encrypted (AES-256-GCM), used exclusively to execute the user's requests, deletable at any time.
• Usage data: per request time, model, number of input and output tokens, cost, response time. Purpose: billing, transparency, abuse prevention (Art. 6 (1) (b) and (f)). The MCP connector does not store request or answer content.
• Billing data: name, company, address, VAT ID, e-mail; retained according to commercial and tax law (Art. 6 (1) (c)).
• Chat workspace: conversations are stored so you can continue them. Content is encrypted with AES-256-GCM, deleted automatically after 30 days and can be deleted by you at any time; “do not store” is available per conversation. Uploaded files are not stored as files, only as extracted text (encrypted, deleted with the conversation); images, audio and video are transmitted to Infercom for text recognition. Hidden text and instruction patterns detected in files or web pages are removed and counted without content. With Verifact switched on, your question is transmitted to our service Verifact (Pioneerdesk GmbH, data centre in Germany); questions without an evidenced answer are stored without personal reference to extend the knowledge base (Art. 6 (1) (f)). Web pages: links in your messages are fetched from our server in Germany; the readable text of public pages is kept in a shared cache without reference to persons; addresses with credentials are not stored. With “Research” enabled, short search queries derived from your question are sent to the configured search provider (our own meta search on our server, or Google Programmable Search, USA; then only the query, never the chat) and result pages are fetched by us.

4. Recipients

• Infercom S.A. (Luxembourg, data centres in Germany): processing of request content to generate the answer. According to Infercom, no requests or answers are stored (zero data retention). With your own key the contract with Infercom is direct.
• Revolut Bank UAB / Revolut Payments: card payments. Payment data are processed exclusively by Revolut; we receive amount, time and status.
• Lexware / Haufe-Lexware GmbH & Co. KG: creation and retention of invoices.
• Brevo (Sendinblue GmbH): sending of system e-mails (activation links, codes, invoices).
• Anthropic, OpenAI or Google: if you use the MCP connector, your assistant (Claude, ChatGPT, Gemini) calls our service on your behalf; their privacy policies apply to what you type there.

5. Cookies and local storage

We only use technically necessary cookies (login session) and store your display preferences (language, light/dark) locally in your browser. No tracking takes place.

6. Your rights

You have the rights to access, rectification, erasure, restriction, data portability and objection (Art. 15 to 21 GDPR) and the right to lodge a complaint with a supervisory authority; the competent authority is the Bavarian State Office for Data Protection Supervision (BayLDA).